Qualitative Assessment Review Guidelines
for Investigative Operations of
Federal Offices of Inspector General
Council of the Inspectors General
on Integrity and Efficiency
Authority: Section 11 of the Inspector General Act of 1978 (5 U.S.C. app. 3.), as
Mission: The mission of the Council of the Inspectors General on Integrity and
Efficiency (CIGIE) shall be to address integrity, economy, and effectiveness issues that
transcend individual Government agencies and increase the professionalism and
effectiveness of personnel by developing policies, standards, and approaches to aid in
the establishment of a well-trained and highly skilled workforce in the Offices of
CIGIE Investigations Committee: The Committee contributes to improvements in
program integrity, efficiency, and cost effectiveness Governmentwide by providing
analysis of investigative issues common to Federal agencies. The Committee provides
the CIGIE community with guidance, support, and assistance in conducting high-quality
investigations. Provides input to the CIGIE Professional Development Committee and
the Training Institute on the training and the development needs of the CIGIE
investigations community. The Committee actively engages the Assistant Inspector
General for Investigations Committee to assist in carrying out the Committee's goals
Message From the Chairman of the
CIGIE Investigations Committee
I am pleased to present the Quality Assurance Review (QAR) Guidelines for
Investigative Operations of Federal Offices of Inspector General (OIGs). Throughout this
version, you will note minor changes for clarification. However, the most significant
addition is a definitional framework to assist QAR teams in evaluating their results and
arriving at a peer review rating.
The purpose of the QAR program, or investigation peer review, is to ensure that Council
of the Inspectors General on Integrity and Efficiency (CIGIE) Quality Standards for
Investigations (QSI) are followed and that law enforcement powers conferred by the
2002 amendments to the Inspector General Act (IG Act) are properly exercised.
Each OIG is required to implement and maintain a system of quality control for its
investigative operations. The nature, extent, and formality of such a system will vary
based on the OIG’s circumstances. The system of quality control encompasses the
OIG’s leadership, with an emphasis on performing high-quality work, compliant with
In conducting a particular QAR, the review team renders an opinion on adequacy of a
given OIG’s internal safeguards, management procedures, and quality control in
connection to compliance with the IG Act, QSI, and law enforcement powers.
I want to thank the Assistant IG for Investigations (AIGI) Working Group for their
diligence in revising these Guidelines with input from the AIGI community. I also want to
thank the Investigations Committee for their review and support in finalizing the QAR
Guidelines. The members of the AIGI Working Group and of the Investigations
Committee are listed in Appendix D.
Carl W. Hoecker
Chairman, Investigations Committee
Table of Contents
GENERAL CONSIDERATIONS 2
Applicability of Appendices 2
Objectives of Investigative Qualitative Assessment Review (QAR) Program 3
Management and Oversight of CIGIE QAR Program 4
Review Team Staffing and Qualifications 5
Confidentiality and Security 5
Due Professional Care 6
Self-Inspection Programs 6
PLANNING AND PERFORMING THE INVESTIGATIVE CIGIE QAR REVIEW 6
Pre-Site Review Steps 7
Working Environment 8
Review Schedule 8
Entrance Briefing 9
Sample Selection 9
Defining and Identifying Observations, Findings, Deficiencies, and Significant Deficiencies 11
QAR Rating Options 12
Views of Responsible Officials 13
Exit Conference 13
REPORTING REVIEW RESULTS 13
Opinion Letter 13
Observations Letter 14
Views of Responsible Officials 15
Dispute Resolution 15
Letter Distribution 16
Files Maintenance 16
A Qualitative Assessment Review Organizational Profile
B Questionnaire for Review of Law Enforcement Powers Implementation
C-1 Questionnaire for Review of Compliance with the CIGIE Quality Standards for Investigations
C-2 Questionnaire for Review of Compliance with Quality Standards for Investigations (Digital
D-1 CIGIE Peer Review Individual Closed Case Review Checklist
D-2 CIGIE Peer Review Case Review Summary Checklist
E Sample Formats for Quality Assessment Review Reports
F Attorney General’s Guidelines for Offices of Inspector General with Statutory Law Enforcement
G-1 Attorney General’s Guidelines for Domestic FBI Operations
G-2 Cover Memo—Attorney General’s Guidelines for Domestic FBI Operations
H Attorney General’s Guidelines Regarding the Use of Confidential Informants
I CIGIE Quality Standards for Investigations
J CIGIE Guidelines on Undercover Operations
This document articulates standards and guidance for conducting the Council of the
Inspectors General on Integrity and Efficiency (CIGIE) Quality Assessment Reviews
(QAR) of the investigative operations of Offices of Inspector General (OIGs). It was
initially developed, and subsequently updated, by the CIGIE Investigations Committee
to establish an independent external review process to:
1. Ensure that the general and qualitative standards adopted by OIGs comply with
the requirements of the Quality Standards for Investigations (QSI) adopted by
CIGIE and its predecessors, PCIE and ECIE. This compliance will be assessed
for all CIGIE organizations.
2. Ascertain whether adequate internal safeguards and management procedures
exist to ensure that the law enforcement powers conferred by the Inspector
General Act, as amended (IG Act), are properly exercised by OIGs with such
authority, pursuant to Section 6(e) of the IG Act and the “Attorney General’s
Guidelines for Offices of Inspector General with Statutory Law Enforcement
Each OIG is required to implement and maintain a system of quality control for its
investigative operations. The system of quality control encompasses the OIG’s
leadership, with an emphasis on performing high-quality work. The policies and
procedures of each OIG should be designed to provide reasonable assurance of
complying with professional standards and applicable legal and regulatory
requirements. The nature, extent and formality of an OIG’s system of quality control will
vary based on the OIG’s circumstances. Each OIG must develop and document its
quality control policies and procedures in accordance with its agency and individual OIG
requirements, then communicate those policies and procedures to its personnel.
These guidelines may be adapted for organizations’ internal reviews (self assessments)
within the CIGIE community. It also provides guidelines for reviewing investigative
processes and records maintenance in any investigative operation.
1. Applicability of Appendices. The following questionnaires and checklists were
developed to assist in conducting the review of an organization.
Appendix A is a profile sheet of administrative data about the organization being
Appendix B is a questionnaire to assess whether adequate internal safeguards
and management procedures exist within those OIGs that exercise law
enforcement powers pursuant to Section 6(e) of the IG Act and the “Attorney
General’s Guidelines for Offices of Inspector General with Statutory Law
Appendix C-1 is a questionnaire to assess compliance with the general and
qualitative standards outlined in the CIGIE QSI. Appendix C-2 is a questionnaire
to assess conformity with digital forensics activities.
Incorporation of Appendix C-2 (a review of digital forensics activities) is not
mandatory. It is an “opt-in” feature of a peer review. If the OIG organization being
reviewed has computer forensic capability, it may, prior to commencement of the
review, opt to have its digital forensics activities reviewed. If an organization does
opt in, the results of the digital forensics review will be included in the overall
assessment of the OIG organization. Please note that regardless of an
organization’s decision to opt in, or out, of a digital forensic review, the
investigative operations of information technology and computer-related units will
be reviewed relative to the QSI (planning, execution and reporting) and Attorney
General’s Guidelines, where appropriate. Appendix C-2 involves an additional
review step—focusing on the technical aspects of digital forensics activities. If the
OIG organization conducting the peer review does not have in-house personnel
with computer forensic capability to conduct the review, it may seek assistance
from other CIGIE OIG organizations.
Appendix D-1 and D-2 are individual and summary checklists, respectively, used
to sample closed investigative case files when testing the degree of compliance
with the Attorney General’s Guidelines and/or the QSI mentioned above.
Appendix E includes sample formats for reporting CIGIE QAR findings.
Appendix F is the “Attorney General’s Guidelines for Offices of Inspector General
with Statutory Law Enforcement Authority.”
Appendix G-1 is the “Attorney General’s Guidelines for Domestic FBI
Appendix H is the “Attorney General’s Guidelines Regarding the Use of
Appendix I is the “CIGIE Quality Standards for Investigations,” dated December
Appendix J is the “CIGIE Guidelines on Undercover Operations,” dated February
2. Background. These guidelines are based primarily on the IG Act, the QSI
(December 2003) and the “Attorney General’s Guidelines for Offices of Inspector
General with Statutory Law Enforcement Authority” (December 8, 2003).
The IG Act has established statutory OIGs in over 70 Federal establishments and
entities, including all cabinet departments and Federal agencies, boards,
commissions, corporations, and foundations and agencies of the Legislative Branch.
The QSI categorizes investigative standards as General and Qualitative. General
Standards address qualifications, independence, and due professional care.
Qualitative Standards focus on investigative planning, execution, reporting, and
The “Attorney General’s Guidelines for Offices of Inspector General with Statutory
Law Enforcement Authority” govern the exercise of statutory police powers by
Inspectors General and eligible employees and the role of Federal prosecutors in
providing guidance in the use of sensitive criminal investigative techniques.
3. Objectives of the Investigative QAR Program. The overall objective of a QAR is
to determine whether internal control systems are in place and operating effectively
to provide reasonable assurance that an OIG is complying with professional
investigative standards, as well as other requirements. This assessment program is
intended to be positive and constructive rather than negative or punitive. With this in
mind, the review team is encouraged to identify “best practices” or similar notable
positive attributes of the organization. Additionally, the review team should view
favorably on-the-spot corrections to non-systemic potential weaknesses. Further,
the team must consider the extent to which the reviewed OIG had/has control over a
potential weakness (e.g., agency is responsible for a particular process such as
inventory control, encryption, background investigations, etc.).
These guidelines are applicable to a diverse set of Federal and non-Federal
organizations, including all cabinet departments, Federal agencies, boards,
commissions, corporations and foundations, and Legislative Branch agencies.
The 2003 edition of the Quality Standards for Investigations were published by the President’s Council on Integrity
and Efficiency (PCIE) and the Executive Council on Integrity and Efficiency (ECIE). These entities were replaced in
the Inspector General Reform Act of 2008 (P.L. 110-409) by the Council of the Inspectors General on Integrity and
Reviewing OIGs should be cognizant of the structure of the organization they are
reviewing and how that OIG has adapted QSI and other professional standards to
the unique circumstances of that respective department or agency. As such,
reviewing OIGs may adapt the guidelines, as appropriate.
4. Management and Oversight of CIGIE QAR Program. The CIGIE Investigations
Committee has responsibility for overall management and oversight of the CIGIE
QAR process. This Committee will resolve all issues that cannot be mutually agreed
upon by the CIGIE QAR team and any OIG being reviewed.
The Chairperson of the CIGIE Investigations Committee is responsible for
establishing a schedule to ensure that OIGs with statutory law enforcement authority
pursuant to Section 6(e) of the Inspector General Act are subject to a CIGIE QAR no
less than once every three years.
The selection of assessment partners must be done in a manner that ensures the
integrity of the peer review process. Peer reviewers must be free, both in fact and
appearance, from impairments to independence. An OIG that received a
noncompliant QAR rating will be deemed unqualified to conduct a QAR of another
OIG until that OIG receives a compliant rating. Generally speaking, where feasible,
assessment partners will be of similar size and have similar law enforcement
powers. The Investigations Committee will coordinate its scheduling efforts with the
CIGIE Audit Committee. The CIGIE QAR schedule should be updated and
distributed with sufficient lead time to ensure OIGs are able to plan their
participation. Absent unique circumstances, participating agencies (reviewer and
reviewed) should be made aware of future peer reviews at least 1 year in advance.
The OIGs involved in a specific peer review may, upon mutual agreement,
accelerate or delay a review by one calendar quarter without prior approval by the
Investigations Committee. The Chair of the Assistant Inspector General for
Investigations (AIGI) subcommittee is responsible for resolving scheduling conflicts
or issues that may arise.
Newly established OIGs or those that do not have statutory law enforcement
authority are strongly encouraged to participate voluntarily in an investigative peer
review every three years. OIGs that seek and obtain 6(e) authority from the Attorney
General must immediately initiate steps to adhere to “Attorney General’s Guidelines
for Offices of Inspector General with Statutory Law Enforcement Authority.”
Compliance with these guidelines will be evaluated during their next scheduled peer
review but not sooner than 3 years following the granting of the authority. Thus,
those OIGs should request the Investigations Committee add their office to the QAR
The function of the CIGIE QAR is considered inherently governmental. The process
must be handled within the Inspector General (IG) community and not contracted
5. Review Team Staffing and Qualifications. Conducting a CIGIE QAR review
requires considerable professional judgment and leadership. The CIGIE QAR team
will consist of a team leader with appropriate investigative background and
experience. It is recommended, but not mandated, that the team leader be at or
above the GS-15 grade level, or equivalent. The rest of the team will consist of OIG
investigators and an administrative support staff from one or more OIGs, as deemed
The team size and composition may vary depending on a number of factors
including, but not limited to: the size and geographic dispersion of the OIG being
reviewed; changes in organizational structure, control and leadership; and the
number, type and importance of reports issued at each field location or satellite
If the organization under review handles classified information, members of the
assessment team must have the appropriate level of security clearance(s) to permit
a complete CIGIE QAR without undue limitation on the quality of the review.
6. Independence. The review team members and their senior management should
meet the independence standards in the “Quality Standards for Federal Offices of
Inspector General” and the CIGIE QSI. To avoid any appearance of bias, care
should be taken to ensure that the CIGIE QAR team members do not have
relationships with the officials in the OIG being reviewed that would be viewed as
lacking impartiality by knowledgeable third parties. The CIGIE QAR team members
should not have been recent employees of the OIG being reviewed. The OIG
managing a CIGIE QAR cannot review an office that conducted its most recent
CIGIE QAR or CIGIE audit peer review. Questions or concerns related to the
composition of a particular QAR team should first be raised with the IG of the review
team. If these issues cannot be resolved, they can be raised with the CIGIE
7. Confidentiality and Security. The CIGIE QAR team should safeguard all
privileged, confidential and national security or classified information in compliance
with applicable laws, regulations and professional standards.
All matters discussed, materials assembled, documents prepared and reports
generated through an external CIGIE QAR should, at a minimum, be treated as
proprietary information and maintained appropriately. To the extent possible,
privileged and confidential information, such as names and other personally
identifying information, should not be recorded in reports issued by the CIGIE QAR
team. The team leader must ensure that the team complies with relevant
professional guidance on the use, protection and reporting of information such as
classified material, Internal Revenue Service tax information and protection of grand
jury material and information.
It is possible that the review team may not be granted access to sensitive material
because of legal restrictions. If this situation occurs, the review team should review
the system related to the maintenance and protection of information to determine the
adequacy of established procedures. Discussion among review team members of
any information obtained during an external review is limited to a need-to-know
8. Due Professional Care. The review team should strive to achieve quality
performance by exercising due professional care and sound professional judgment
in planning, performing and reporting the results of the review.
9. Self-Inspection Programs. Some OIGs have an internal self-inspection program. If
so, the OIG being reviewed will furnish a copy of any internal self-inspection reports
that have been completed since the last peer review to the new CIGIE QAR team.
The reviewed OIG may provide the QAR team with a copy of the self-inspection
report before the onsite review. Additionally, the reviewed OIG may limit disclosure
to only those portions that relate to areas covered by the peer review. Removal
and/or copying of the internal report may be restricted by the reviewed OIG. The
QAR team may consider information from the self-inspection program; however,
such information will not be the sole basis for the overall QAR rating.
PLANNING AND PERFORMING THE INVESTIGATIVE CIGIE QAR REVIEW
As stated above, the objective of a QAR is to determine whether internal safeguards
and management procedures are in place and operating effectively to provide
reasonable assurance that established policies, procedures and applicable investigative
standards are being followed. In making this determination, the CIGIE QAR team will
analyze existing policies and procedures, conduct interviews with selected management
officials and the investigative staff, and sample closed investigative files and other
administrative records, as warranted.
The documentation required for a full peer review is completion of the CIGIE QAR
Appendices A, B (if applicable), C-1, C-2 (if applicable), D-1, and D-2. For agencies not
governed by the law enforcement powers conferred by the 2002 amendments to the
Inspector General Act (Section 6(e)), the scope of the review may be limited or
expanded based on the agreement of the reviewed organization and the CIGIE QAR
Appendix A – This section is an organizational profile of the office being reviewed.
Appendix B – If applicable, this section of the CIGIE QAR assesses whether an
organization meets the requirement of statutory law enforcement implementation.
An OIG that received statutory law enforcement powers under legislation other than
Section 6 of the IG Act may be reviewed in accordance with its criteria.
Appendix C-1/C-2 – This portion of the CIGIE QAR process tests an office’s general
conformity with the CIGIE QSI.
Appendix D-1/D-2 – This portion of the CIGIE QAR includes checklists for sampling
closed investigative files for their compliance with applicable law enforcement
standards and the CIGIE QSI.
Answers to certain questions in appendices B, C-1 and D-1 may not be readily
available or apparent based on available documentation and information. In these
instances, the peer review team should assess whether there is clear, specific and
articulable information in the case file or from other sources it has reviewed to
suggest the standard was violated. In the absence of such information, the
appropriate answer is “yes” to the corresponding question indicating “in compliance.”
2. Approach. Review team members should be knowledgeable of all facets of an
investigation and use prudent judgment when evaluating compliance with the
Inspector General Act, the CIGIE QSI, applicable law enforcement guidelines and
OIG policies and procedures. To the extent possible, teams will review offices with
similar law enforcement authorities and structures.
Generally, review teams will be assessing the following:
Whether the organization has policies, procedures or programs in place to
facilitate compliance with the Attorney General’s Guidelines and/or the CIGIE
Whether the organization has policies, procedures or programs in place to
facilitate the identification and correction of non-compliance.
Whether the organization complies with the above policies, procedures or
3. Pre-Site Review Steps. The organization being reviewed will complete Appendix A
in its entirety and only the “Reviewed Agency Policy/Manual Reference” column of
Appendix B (if applicable) and Appendix C-1 as well as Appendix C-2 (if applicable).
Hyperlinking responses to relevant document cites is optional, but encouraged. It is
preferable that this documentation be furnished electronically to the CIGIE QAR
team for analysis before a site visit begins. The review team should always consider
obtaining and reviewing relevant policy and procedural documentation to save time
In advance of a peer review, the reviewed OIG should indicate with an “N/A” those
questions that do not apply to the organization. OIGs are strongly encouraged to
provide explanatory comments for any questions it feels warrant “N/A.” These
comments will aid the assessment by the reviewing organization.
Examples of references and other documentation that should be available for the
review team to examine prior to the onsite review include:
a. Manuals, Policy Statements and Handbooks – pertinent documents describing
the operational policies and procedures.
b. Semiannual Reports to Congress – at least the four most recent semiannual
reports to Congress. (The semiannual reports will provide information regarding
the nature and volume of investigative work being performed. The reports may
also assist the review team in identifying closed case files to be reviewed.)
c. A copy of the office’s last CIGIE QAR report and a summary of the
corrective action taken in response to CIGIE QAR findings.
d. Closed Case Inventory – a listing of the cases closed during the past 12
months. (This listing should include information such as the case identifiers;
dates the investigations were opened and closed; case types (e.g., employee
integrity or procurement fraud); referral dates; disposition; types of action taken;
hours charged; and grade levels of the investigators.)
e. Self-Inspection Report – a copy (or appropriate portions) of self-inspection or
internal evaluation reports conducted by the organization may be provided in
advance or held until the onsite visit.
Requests for information should be submitted to the OIG being reviewed
approximately 60 to 90 calendar days before the onsite review begins.
4. Working Environment. Before beginning the on-site work, the CIGIE QAR team
leader should arrange with the reviewed agency to have adequate workspace for the
review team. The AIGI, or a designee, should facilitate the coordination of logistics
for the CIGIE QAR team and in obtaining requested materials.
5. Review Schedule. The CIGIE QAR will be scheduled by mutual agreement
between the review team and the agency to be reviewed. Once a tentative schedule
is established, the reviewing organization should send the reviewed organization an
engagement letter modeled on the example in Appendix E. The size of the
organization or level of detail of the review may impact the time required to complete
The goal of the review team should be to complete a QAR efficiently. Therefore, the
following timeframes are provided as general guidance:
Action Item Recommended Timeframe
Appointment of CIGIE QAR team 90 days before the site review
leader and selection of review team.
Send engagement letter to reviewed 90 days before the site review
Conduct pre-site review and request 60 to 90 days before the on-site review
necessary information from office begins
Conduct on-site review. 5 to 10 days
Complete the draft CIGIE QAR report 30 days after completing the on-site review
and submit the draft report to the
reviewed office for comment in an
Allow offices being reviewed to 15 days upon receipt of report
comment on the draft report.
Finalize CIGIE QAR report and 15 days after receipt of comment(s) by
related documents and distribute. reviewed office
Memorandum from reviewed agency 60 days after issuance of final report
on the status of corrective actions it
committed to implement.
6. Entrance Briefing. An entrance briefing will be conducted with the IG or designee of
the OIG being reviewed. The senior investigations personnel from each field office
reviewed should be invited to attend the entrance briefing. This meeting provides an
opportunity to outline the objectives of the CIGIE QARs, review the methodology and
address any areas of management concern.
7. Sample Selection. It may be prohibitive in terms of time and resources for the
review team to examine each field location and the entire population of OIG records
to answer specific items in the appendices.
The selection of field locations (satellite offices) included in the review involves the
exercise of considerable professional judgment. The review team should strive to
include offices that are representative of the OIG with greater weight given to
locations with a lower level of centralized control. If prior internal inspections show a
location had problems in the past, the team may want to review a sample of that
location’s work to ensure that corrective actions have been implemented and, if so, if
they were effective.
Factors to be considered in selecting the field location(s) to be reviewed include the
Number, size and geographic dispersion of field offices
Changes in organizational structure, control and leadership
Number, type and importance of reports issued by location
Degree of centralized control over field locations
Results of prior internal inspection reports or other external reviews
The need to verify the results of internal inspection reports
Due to the sensitive and dynamic nature of active investigations, it is recommended
that the review team sample closed cases during the CIGIE QAR (see Appendix
D-1/D-2). In determining the number of closed cases in the sample, it should be kept
in mind that the objective of the CIGIE QAR is to obtain information regarding the
performance of the OIG overall, not each individual office. Therefore, team leaders
should not feel that they need to select a certain number of reports at each location;
rather, to the extent possible, the sample selection should facilitate the review of a
cross-section of investigation types performed by the OIG staff at the location (e.g.,
procurement fraud, environmental crimes, technology crimes, traditional crimes,
employee misconduct, etc.). Additionally, the review team may, at its discretion,
review closed cases from prior years for further validation if the original sample is
either too small or suggests potential significant deficiencies. However, the review
team generally should not examine cases closed more than two years prior to the
The following guidance is furnished to assist the review team in determining the
number of closed cases selected in the sample:
Number of Cases Closed
Minimum Number of Closed Cases In the
In the 12 Months
Preceding On-site Work
0-20 All Files
21 – 100 Cases 20 Closed Cases
101 – 500 Cases 30 Closed Cases
500 (or more) Cases 50 Closed Cases
The review team must apply a no-advance-notice policy in advising the OIG of the
closed case files selected for review during the on-site visit, if legally possible.
Sampling may also be used to perform the following review steps:
a. Reviewing documentation to determine whether investigators meet the basic
qualifications for investigators.
b. Review of training profiles, or the equivalent, to ensure investigators maintain
their investigative and law enforcement skills.
8. Defining and Identifying Observations, Findings, Deficiencies, and Significant
Deficiencies. Determining the relative importance of matters noted during the peer
review, individually or combined with others, requires professional judgment. Careful
consideration is required in forming conclusions. This includes assessing the nature,
cause(s), pattern and pervasiveness of an issue.
The descriptions that follow are intended to assist in aggregating and evaluating the
peer review results, forming conclusions and determining the rating of the peer
review report to issue:
a. Observation. An “observation” generally occurs when one or more “No” answers
are recorded for questions in a peer review checklist (e.g., Appendices B, C and
b. Finding. A “finding” is one or more related observations that result from a
condition in the organization’s system of quality control or compliance with it such
that there is more than a remote possibility that the organization would not
perform, or did not perform, in conformity with its policies and procedures,
applicable professional standards or related requirements. A review team will
assess whether one or more findings are a deficiency. If the review team
concludes that no finding, individually or combined with others, rises to the level
of deficiency, a report rating of compliant is appropriate (see below).
c. Deficiency. A “deficiency” is one or more findings that result from a condition in
the organization’s system of quality control or compliance with it such that there
is reasonable likelihood that the organization would not perform, or did not
perform, in conformity with its policies and procedures, applicable professional
standards or related requirements. A review team will assess whether one or
more deficiencies constitute a significant deficiency. If the review team concludes
that no deficiency, individually or combined with others, rises to the level of
significant deficiency, a report rating of compliant is appropriate (see below).
Deficiencies will be reported to the reviewed OIG with suggestions for
d. Significant Deficiency. A “significant deficiency” is one or more deficiencies that
result from a condition in the organization’s system of quality control or
compliance with it such that there is a high probability that the organization would
not perform, or did not perform, in conformity with its policies and procedures,
applicable professional standards or related requirements. A significant
deficiency is generally limited to a material failure(s) to conform with critical
elements of the CIGIE Quality Standards for Investigation and/or the Attorney
General’s Guidelines for Statutory Law Enforcement Authority and related
requirements. A significant deficiency indicates a breakdown in practices,
programs and/or policies that had an actual notable adverse impact on, or has a
likelihood of materially affecting, the integrity of the investigative process (e.g.,
planning, conducting, reporting) or law enforcement operations (i.e., powers
conferred by the IG Act). If the review team identifies one or more significant
deficiencies, a report rating of noncompliant is appropriate. Significant
deficiencies will be reported to the reviewed OIG with recommendations for
correction and/or improvement.
In each of the above instances—observation, finding, deficiency and significant
deficiency—the peer review team must consider the nature, causes, pattern, materiality,
pervasiveness and relative importance to the issue or system of quality control as a
whole. The OIG under review must be afforded the opportunity to provide explanatory or
mitigating information prior to the review team reaching a conclusion.
The following circumstances generally do not give rise to a noncompliant finding:
Issues were found in a limited number of case files or at one of several sites
An issue existed in an area outside the exclusive or substantial control of the
The reviewed OIG lacked stand-alone internal written policy but, in practice,
complied with applicable standards; and,
The organization violated its own internal policy, but has complied with the
CIGIE QSI and the Attorney General’s Guidelines (e.g., internal policy
documents require training at a shorter interval than it actually conducts, but
its practice, although violating its policy, is consistent with the QSI and
Attorney General’s Guidelines).
9. QAR Rating Options. The CIGIE QAR team has the following two options for
assessing an OIG’s overall performance:
Compliant A rating of “compliant” conveys that the reviewed organization
has adequate internal safeguards and management
procedures to ensure that CIGIE standards are followed and
that law enforcement powers conferred by the IG Act are
properly exercised (for applicable agencies). An OIG with one
or more significant deficiencies may not receive a compliant
Noncompliant A rating of non-compliance indicates a breakdown in
practices, programs and/or policies that had an actual notable
adverse impact on, or has a likelihood of materially affecting,
the integrity of the investigative process (e.g., planning,
conducting, reporting) or law enforcement operations (i.e.,
powers conferred by the IG Act).
10. Views of Responsible Officials. CIGIE QAR assessments must be both complete
and fair. Exaggeration of an issue’s significance must be avoided. One way to
ensure the objectiveness, accuracy, and completeness of the findings is to obtain
the views of responsible officials prior to finalizing the assessment. When tentative
observations, findings or deficiencies are found, the team must discuss the situation
with the appropriate responsible official(s) designated by the reviewed OIG during
the review. On-the-spot corrections will be viewed favorably, but must be completed
prior to the issuance of the final report. Depending on the gravity of the matter
corrected on the spot, the issue—and corresponding corrective action—may be
discussed in either the opinion letter or letter of observations. All preliminary
observations, findings, deficiencies or significant deficiencies must be presented
during the review to the official(s) designated by the reviewed OIG prior to issuing
the draft report. This action will help avoid any misunderstandings and aid in
ensuring that all facts are considered before a formal draft report is prepared.
11. Exit Conference. The review team must prepare and present the draft report to the
IG and other members of the senior management team at the conclusion of the on-
REPORTING REVIEW RESULTS
The QAR Report consists of an Opinion Letter and an optional Observations Letter. See
1. Opinion Letter. This letter is prepared by the CIGIE QAR team and furnished to the
IG of the reviewed organization. The body of the opinion letter contains information
a. Scope of the review, including any limitations thereon, and any expansion of the
review beyond the basic review guide, if applicable.
b. Description of the review methodology, including the field offices visited and a
listing, by case number, of each investigative file reviewed.
c. The review team’s opinion regarding the compliance or non-compliance with
CIGIE QSI and applicable law enforcement standards.
d. An explanation of review team actions taken in response to the OIG’s official
comments to the draft report.
If a rating of noncompliant is reported, all significant deficiencies that served as the
basis for the rating must be included in an attachment. The significant deficiencies must
be supported by clear and convincing evidence of noncompliance, as well as a specific
listing of the standard(s) violated.
A non-complaint rating will also be accompanied by recommendations for corrective
action and/or improvement. Such recommendations for corrective action and/or
improvement should be discussed with the reviewed OIG prior to finalizing the opinion
letter. The review team will work closely with the Investigations Committee to determine
if the reviewed OIG will be required to provide periodic updates on the status of
implementing recommendations. The timing and form of such updates, and to whom
they will be provided, will also be determined in coordination with the CIGIE
Investigations Committee. Recommendations will be closed upon mutual agreement
between the Investigations Committee and reviewed OIG. They will remain open or not
fully implemented until that time. The Investigations Committee will review and resolve
disputes in this area. Significant deficiencies and associated recommendations may be
reportable in an organization’s Semiannual Report to Congress.
2. Observations Letter. A supplemental observations letter may optionally be
furnished to the IG of the reviewed office. Observations may fall into two categories:
a. “Best Practices” or similar notable positive attributes of the organization.
In keeping with the constructive nature of the CIGIE QAR program, the reviewing
agency will highlight practices, policies, programs, accomplishments, etc., that
are particularly worthy of praise or acknowledgement. Examples include, but are
not limited to, a comprehensive management development program, an
advanced management information system and quality report writing and
In coordination with the reviewed agency, the team should report particularly
noteworthy accomplishments found during the review to the CIGIE Investigations
Committee for dissemination. Other OIGs may benefit from this information. This
may be done in a separate letter from the team leader to the Committee.
b. Areas for Improvement or Increased Efficiency/Effectiveness. Peer review
teams may offer suggestions for improvement or increased
efficiency/effectiveness based on observations, findings and deficiencies
identified. The reviewing team will identify a specific applicable Quality Standard
or Attorney General’s Guideline as a benchmark. Isolated instances of policy or
procedural nonconformity, or non-systemic events or conditions, are included
here. For example, a review team could identify policies or programs that are
inconsistent with applicable standards. Implementation of the suggestions is
done at the discretion of the reviewed OIG and will not be tracked or monitored
by the review team.
3. Views of Responsible Officials. The OIG being reviewed must be afforded an
opportunity to comment on the formal draft report prior to the issuance of a final
assessment report. All material facts provided by the reviewed organization must be
considered by the review team to determine whether the initial comments included in
the draft report should be revised.
4. Dispute Resolution. The reviewed OIG may seek informal advice and guidance
from the Investigations Committee regarding any concerns about draft findings or
deficiencies. The IG of the reviewed organization may formally refer a dispute about
a draft significant deficiency to the CIGIE Investigations Committee for review and
resolution, if the IG cannot resolve the matter with the CIGIE QAR team. The IG of
the reviewed organization should provide the Investigations Committee: (a) a copy of
the draft CIGIE QAR report and attachments, (b) the reviewed organization’s
response to the draft CIGIE QAR findings, and (c) a written summary of the material
facts regarding the disagreement.
The Investigations Committee should work with the OIG being reviewed and the
CIGIE QAR team leader to resolve the dispute. A range of options are available to
the Investigations Committee. For example, the Investigations Committee may elect
to: (a) accept the CIGIE QAR team’s initial conclusion related to a significant
deficiency; (b) accept the reviewed organization’s explanations; (c) request the
CIGIE QAR review team conduct additional work to facilitate the resolution of the
disagreement; (d) form a new CIGIE QAR team tasked with conducting further
review of the disputed findings; or (e) other options not specifically anticipated here.
As mentioned previously, the Investigations Committee should be furnished a copy
of each final CIGIE QAR report conducted in CIGIE organizations. If the reviewed
organization receives an overall opinion rating of “noncompliance,” the organization
must provide the Investigations Committee a detailed corrective action plan to bring
the organization into compliance with professional standards. Where appropriate,
this plan will be made available to the U.S. Department of Justice upon request. An
organization receiving an overall noncompliance rating will not be allowed to conduct
CIGIE QAR reviews at other agencies until the corrective action plan has been
developed and the CIGIE Investigations Committee has approved its
5. Letter Distribution. The review team will distribute the final peer review results as
a. Reviewed OIG: Original Opinion Letter and Observations Letter(s).
b. CIGIE Investigations Committee: Copies of Opinion Letter (including
attachments) and Observations Letter(s) will be sent to:
Council of the Inspectors General on Integrity and Efficiency
1717 H Street, NW, Suite 825
Washington, DC 20006
c. Attorney General: Copy of Opinion Letter, including any attachments, only for
those agencies that receive their law enforcement authority pursuant to
Section 6(e) of the IG Act. This letter will be sent directly to the Attorney
U.S. Department of Justice
Attn: Attorney General (CIGIE Investigative Peer Review)
950 Pennsylvania Avenue, NW
Washington, DC 20530-0001
Additionally, consistent with the CIGIE Quality Standards for Federal Offices of
Inspector General, a reviewed OIG may provide a copy of the final letters resulting
from the CIGIE QAR to the head of the agency or department and/or make the
results publicly available.
6. Files Maintenance. All files, records, notes, memoranda or other documents
obtained from the office reviewed will be returned after issuing the final report. The
OIG conducting the CIGIE QAR should retain a copy of the final report and
supporting appendices. It is recommended that these documents be retained by the
reviewing OIG for at least two review cycles.
The OIG conducting the CIGIE QAR will institute a record retention policy in
accordance with guidelines established by the National Archive and Records
Administration. All requests for access to the CIGIE QAR files, to include Freedom of
Information Act (FOIA) and Privacy Act (PA) requests, must be processed in
consultation with the reviewing and reviewed IG and the CIGIE Executive Director.
The individuals below were contributors for this revision of the QAR Guide.
The QAR working group consisted of the following AIGIs:
P. Brian Crane, AIGI, Treasury OIG
Peggy L. Fischer, AIGI, NSF OIG
John R. Hartman, DIG, DOE OIG
Kimberly A. McKinley, DIG for Investigations, OPM OIG
Douglas J. Morgan, Jr., SAC, NSF OIG
James J. O'Neill, AIGI, VA OIG
Michelle B. Schmitz, AIGI, OPM OIG
William R. Siemer, AIGI, USPS OIG
Robert J. Walters. Acting DIG, CNCS OIG
Investigations Committee Members
Chair: Carl W. Hoecker IG, U.S. Capitol Police
Co-chair: Eric M. Thorson IG, Treasury Department
Members: Lanie D’Alessandro IG, National Reconnaissance Office
Charles K. Edwards Acting IG, Department of Homeland Security
Arthur A. Elkins IG, Environmental Protection Agency
Michael G. Carroll Acting IG, Agency for International Development
J. Russell George IG, Treasury Inspector General for Tax
Peggy E. Gustafson IG, Small Business Administration
Allison C. Lerner IG, National Science Foundation
John P. McCarty Acting IG, Department of Housing and Urban
Brian D. Miller IG, General Services Administration
George J. Opfer IG, Veterans Administration
Jon T. Rymer IG, Federal Deposit Insurance Corporation
Cynthia A. Schnedar Acting IG, Department of Justice
Karl W. Schornagel IG, Library of Congress
Kathleen S. Tighe IG, Department of Education
The following individuals contributed substantially to the final product:
William D. Hamel, AIGI, ED OIG/AIGI Committee Chair
Glenn P. Harris, General Counsel, SBA OIG